Digital assets are changing the ethics landscape for federal employees. The Office of Government Ethics (OGE) has made it clear that cryptocurrency ethics rules for government employees extend under existing law to both cryptocurrencies and stablecoins.
Under 18 U.S.C. § 208, federal employees may not participate in matters that affect their own financial interests. That restriction applies to digital assets as well, putting them in the same category as stocks, bonds, or real estate when it comes to potential conflicts.
As these assets become more prevalent, it’s essential to understand how federal ethics laws apply, identify potential conflicts, and outline the steps employees can take to remain compliant.
Why Digital Assets May Pose Conflicts of Interest
Owning digital assets can create what federal ethics rules call a “disqualifying financial interest.” Under 18 U.S.C. § 208, even a relatively small holding could be enough to trigger concerns if your official duties have a direct impact on the asset’s value.
For example, an employee involved in drafting policy on blockchain regulation may need to step aside if they hold cryptocurrency. Someone working on tax guidance related to digital tokens could face the same issue. Even cybersecurity professionals may encounter conflicts if their role involves digital asset exchanges or blockchain infrastructure.
The key point is that the size of the investment is not always a determining factor. A modest digital wallet can raise questions if an employee’s job duties overlap with the specific area that drives its value.
What Federal Employees Should Do
Federal employees need to actively assess whether digital assets put them at risk of an ethics violation. Start by reviewing your holdings and asking if your job duties influence their value. Even a small or indirect connection deserves attention.
Bring any concerns to your agency’s ethics official. They can confirm whether your situation falls under 18 U.S.C. § 208 and advise on next steps.
Options are straightforward:
- Step back from certain assignments,
- Sell the asset, or
- Shift responsibilities so your work doesn’t overlap.
If you’re subject to financial disclosure, check whether digital assets must be reported — failure to disclose can create its own problems. Taking these steps keeps you compliant and protects the integrity of public service.
Learn more about your retirement benefits at our No-Cost webinars, featuring Ed Zurndorfer -
Practical Tips for Managing Digital Asset Ownership
Federal employees can take several steps to stay ahead of ethics concerns:
- Maintain clear records of digital asset holdings and transactions to quickly disclose them if requested.
- Recognize volatility and how sudden swings in value can amplify a conflict of interest digital assets may trigger.
- Step back when needed by avoiding participation in workplace discussions or assignments that directly involve oversight of digital assets.
- Talk early with ethics officials, since proactive conversations protect both careers and reputations.
Staying Compliant While Planning Ahead
Digital assets count as financial interests under ethics law, just like stocks or real estate. If your job affects their value, that creates a disqualifying conflict of interest. Review your holdings, speak with your agency’s ethics official, and act quickly — recuse yourself or divest if required.
Ethics and financial planning should move together. A CERTIFIED FINANCIAL PLANNER™ (CFP®) can help you manage digital assets in line with long-term goals while avoiding problems at work. Staying alert to cryptocurrency ethics rules for government employees keeps you compliant and protects your career.
Reach out to the team at Serving Those Who Serve at [email protected] for guidance tailored to your situation.
Prior to making an investment decision, please consult with your financial advisor about your individual situation. The prominent underlying risk of using bitcoin as a medium of exchange is that it is not authorized or regulated by any central bank. Bitcoin issuers are not registered with the SEC, and the bitcoin marketplace is currently unregulated. Bitcoin and other cryptocurrencies are a very speculative investment and involves a high degree of risk. Investors must have the financial ability, sophistication/experience and willingness to bear the risks of an investment, and a potential total loss of their investment.
The information has been obtained from sources considered reliable but we do not guarantee that the foregoing material is accurate or complete. Any opinions are those of Serving Those Who Serve writers and not necessarily those of RJFS or Raymond James. Any information is not a complete summary or statement of all available data necessary for making an investment decision and does not constitute a recommendation. Investing involves risk and you may incur a profit or loss regardless of strategy suggested. Every investor’s situation is unique and you should consider your investment goals, risk tolerance, and time horizon before making any investment or financial decision. Prior to making an investment decision, please consult with your financial advisor about your individual situation. While we are familiar with the tax provisions of the issues presented herein, as Financial Advisors of RJFS, we are not qualified to render advice on tax or legal matters. You should discuss tax or legal matters with the appropriate professional. **
